Ireland – Covid-19 – Immigration update

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Update: January 7^th, 2020

Further automatic extension for residence permissions in Ireland announced

What is the change?

The Irish government has announced that foreign nationals with valid immigration permission that expires between Jan. 21, 2021, and April 20, 2021, will be granted an automatic extension until April 20, 2021. Officials also closed the Burgh Quay Registration Office on Dec. 24 until further notice.

• Implementation time frame: This change is set to take effect immediately. No further extensions are anticipated after April 20, 2021. The Burgh Quay Registration Office will remain closed until further notice.
• Who is affected: All foreign nationals residing in Ireland with valid immigration residency permission (based on employment, studies, dependant family, tourism, etc.) that is due to expire between January 21 and April 20.
• Next steps: Employers should update employees with upcoming Irish Residence Permit expiries.

Any individuals who have First Time Registration appointments scheduled at the Burgh Quay Registration Office on or after Dec. 24, 2020,should not attend their appointment. If the appointment falls during the office closures, then it will be prioritized for re-scheduling once the office re-opens.

Individuals located in Dublin who need to renew their IRP permission can still do so using the online renewal platform. These applications will continue to be accepted during the closures.

Background

The Irish government has made this decision in line with recent restrictions as part of its response to COVID-19.

In Ireland, all non-EEA nationals must apply for an employment permit to work. For certain nationalities, individuals must then apply for an entry visa to enter Ireland to commence work. Once in Ireland, all non-EEA nationals must apply for an Irish Residence Permit to register their permission and reside. This Irish Residence Permit must be renewed in Ireland when appropriate by the non-EEA national.

This automatic extension comes after the previous five extensions that were implemented last year on March 20, May 13, July 16, Aug. 20 and Sept. 18. Any permission that was renewed by these previous notices and now has a new expiry date between Jan. 21 and April 20, 2021, is automatically renewed by this notice until April 20.

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Update: October 16^th, 2020

All countries removed from ‘Green List,’ restriction of movement now required for anyone coming to Ireland

What is the change?

The Irish Government has removed all countries from its COVID-19 “green list.”

Anyone entering the state must restrict movement in Ireland when they arrive from another country. Individuals will be required to restrict their movement in Ireland for 14 days immediately upon entry. Individuals travelling from Northern Ireland are exempt from the requirement to restrict movements or self-isolate.

• Implementation time frame: This change took effect Oct. 12.
• Who is affected: Anyone who is travelling to Ireland from another country is affected.
• Next steps: Employers should note that any employees entering Ireland need to restrict their movement for 14 days and will therefore be unable to work in any location other than their private residence.

The Irish government made this decision as part of their efforts to mitigate the spread of COVID-19 and the government’s general advice still states that non-essential travel is to be avoided at this time. Employers and employees should be aware that this restriction of movement may affect employment start dates should the employee be required to restrict their movement for 14 days in Ireland.

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Update: September 23^rd, 2020

Further automatic extension for residence permission in Ireland

What is the change?

The Irish government has announced that foreign nationals with valid immigration permission that expires between Sept. 20 2020 and Jan. 20, 2021, will be granted an automatic extension to Jan. 20, 2021.

• Implementation time frame: This change is set to take effect immediately. No further extensions are anticipated after Jan. 20, 2021.
• Visas/permits affected: Any valid immigration permission (e.g., based on employment, studies, dependant family, tourism, etc.) that expires between Sept. 20 and Jan. 20, 2021.
• Who is affected: All foreign nationals residing in Ireland with valid immigration permission due to expire during this time period.
• Next steps: Employers should update their employees with upcoming Irish Residence Permit expiries.

In Ireland, all non-EEA nationals must apply for an employment permit to work. For certain nationalities, individuals must then apply for an entry visa to enter Ireland to commence work. Once in Ireland, all non-EEA nationals must apply for an Irish Residence Permit to register their permission and reside. This Irish Residence Permit must be renewed in Ireland when appropriate by the non-EEA national.

The recent extension is part of Ireland’s response to the COVID-19 pandemic and comes after four previous extensions were granted on March 20, May 13, July 16 and Aug. 20. Any permission that was renewed by the four previous extensions and as a result expires during the period from Sept. 20 to Jan. 20, 2021, has also been automatically renewed.

The most recent measure was introduced to allow foreign nationals additional time to renew their permissions prior to Jan. 20, 2021. This ensures that employees retain their permission under the same conditions during this time. It is important to note that foreign nationals will not receive an updated permission as part of this announcement. If they wish to travel before renewing their residency permission, we would advise contacting our Deloitte immigration team in advance of departing Ireland.

All renewals in the Dublin area are now being processed online only. This system has been available since 20 July 2020. We are seeing delays in the processing of these applications currently.

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Update: July 21^th, 2020

Further automatic extension for residence permission

What is the change?

The Irish government has announced that foreign nationals with valid immigration permission, which expires between 20 July and 20 August will be granted an automatic one-month extension.

Key points:

• This measure addresses the temporary closure of Irish immigration registration offices where foreign nationals would be required to register their immigration permission once in Ireland.
• All foreign nationals residing in Ireland with valid immigration permission (based on employment, studies, dependant family, tourism etc.) due to expire between 20 July and 20 August will receive an automatic one-month extension. Additionally any permission which was renewed by the two previous automatic extensions and, thus, expires during the period of 20 July and 20 August is automatically renewed by this notice for a further one month.
• Employers should notify their employees of upcoming Irish Residence Permit expiration. Employees based in Dublin should also be prepared to use the online IRP renewal platform announced on 7 July. For more information, click here.

This one-month automatic extension will allow individuals based in Dublin more time to use the online IRP renewal platform. Anyone whose IRP permission is due to expire in one month and who is based in Dublin may use the online IRP renewal service to review permission and apply for a new IRP card. This platform will be fully available for use after 20 July. Individuals will need to be in Ireland to use this online renewal service. Individuals based outside of Dublin will be required to visit their local registration offices. We recommend they contact their local registration office regarding its reopening plans.

The third automatic extension of immigration permission for a further one month is a welcome announcement as it provides certainty to employers and employees whose permission was due to expire. This ensures that employees retain their permission under the same conditions during this time. It is important that employers review their upcoming expiries and update the expiry date by a further month.

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Update: July 15^th, 2020

The Irish government has announced that the Irish Short Stay Visa Waiver Programme will be temporarily suspended

What is the change?

The Irish government has announced that the Irish Short Stay Visa Waiver Program will be temporarily suspended as part of COVID-19 measures to restrict travel and protect public health. The program had allowed certain nationalities visiting the United Kingdom on short stay visas to also travel to Ireland. Under the agreement, the visa holders had to leave Ireland before their permission to stay in the UK ended.

Key points:

• Implementation time frame: 10 July 2020
• Who is affected: Nationals of 17 countries who hold a UK short stay visa were previously able to use this to enter Ireland, provided they could meet certain requirements. Nationals of the affected countries will no longer be in a position to use their UK short stay visa for a visit to Ireland, but may apply separately for an Irish visa, which under current circumstances would only be accepted if it was a critical case. It is noted that this is a temporary measure, which does not affect the Common Travel Area rights of British/Irish citizens, or the operation of the Common Travel Area.
• Next Steps: Employers should update all employees who may be travelling to Ireland utilising this program. Nationals of the affected countries will now need to apply for a separate Irish short stay visa. Please note that many embassies are currently restricting issuance to priority/emergency cases.

Deloitte notes the suspension of the program is being implemented because of a divergence in approach between Ireland and the UK in travel measures to combat the pandemic. It is further noted that this is a temporary measure, which does not affect the Common Travel Area rights of British/Irish citizens, or the operation of the Common Travel Area.

The Government has committed to publishing a Green List of countries on 20 July 2020. This will give clarity in respect of countries which are in a similar position to Ireland in terms of the disease. People entering Ireland from Green List countries will not need to restrict their movements on arrival and the suspension may be reviewed at that time.

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Update: July 9^th, 2020

Residence permit renewals can now be completed online

What is the change?

The Irish government has announced that Irish Residence Permit (IRP) holders in Dublin may now renew their residence permit online rather than having to attend an in-person appointment. Additionally the Burgh Quay (Dublin) Registration Office will re-open for first-time registration appointments July 20.

Key points:

• From July 7, the online IRP renewal system is available for non-EEA nationals whose residence permit has expired, or expires in the next month and who have an urgent need to travel.
• From July 20, the online system will be open to all individuals whose IRP/GNIB cards have expired, or are due to expire in the next month.
• From July 20, non-EEA nationals seeking to complete their first time registration in Ireland may visit the Burgh Quay Registration Office.
• This development will affect all holders of an IRP card who are resident in Dublin. All stamp types are eligible for renewal. Non-EEA nationals can use the online renewal platform if their IRP card expires within a month from the online submission date.
• Employers should notify all employees who hold an IRP card and are resident in Dublin. Those whose IRP cards have expired, or expire in the next four weeks, and who have an urgent need to travel, should apply for their renewal online here and will be required to create an online account. To complete the renewal application online, they must upload the relevant documents to the online platform. Employees should be aware that they may not be able to travel until they receive their passport and renewed IRP card.

Deloitte welcomes this permanent change to the IRP renewal process, as it will allow the resumption of IRP renewals, without the need for an in-person appointment. It also removes the challenge of booking an IRP appointment at the Burgh Quay Registration Office and should make more appointments available for first time registrants. It further allows non-EEA nationals more flexibility in renewing their permission. The resumption of IRP renewals will also allow visa-required nationals to obtain permission to travel and re-enter Ireland.

We expect a high volume of applications because of office closures; therefore, non-EEA nationals should anticipate a potential delay in receiving their renewed IRP cards and passports. As this is the first time this system will have such a significant number of applicants, it is possible that further updates may be issued regarding the process and documents required.

This change will not affect non-EEA nationals who have not yet registered and received their first IRP card in Ireland, and these individuals will still need to book and attend an in-person appointment.

Immigration Service Delivery (that manages the process) deals with registrations for those resident in Dublin. The Garda Naturalisation and Immigration Bureau (GNIB) deals with applications outside of Dublin through the Garda Station network. GNIB is currently considering how it can reopen registration offices countrywide while adhering to public health guidelines, and applicants should contact their local office to confirm when they will reopen.

If you have employees or potential new hires who may be affected by the above changes, please contact the Deloitte immigration team. We have created a guidebook for non-EEA nationals that explains how to set themselves up in the system and how we will support them through this new process. We continue to update our FAQ for employers found here.

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Update: May 18^th, 2020

Further automatic extension for residence permissions

What is the change?

The Irish government has announced that foreign nationals with valid immigration permission that expires between May 20 and July 20 will be granted a further automatic two-month extension. This follows the previous two-month extension that came into effect on March 20, meaning that some permissions may be extended for a total of four months.

This measure is in response to the temporary closure of the Irish immigration registration offices where foreign nationals are required to register their immigration permission once in Ireland.

Key points:

• Implementation time frame: This change is set to take effect of the May 20.
• Who is affected: All foreign nationals residing in Ireland with valid immigration permission (based on employment, studies, dependent family, tourism, etc.) that is due to expire between May 20 and July 20.
• Additionally, any permission which was renewed by the March 20 notice and therefore has a new expiry date between May 20 and July 20 is automatically renewed by this notice for a further two months.
• Next steps: It is important that employers review their upcoming expirations and update the expiry date by a further two months.

All non-EEA nationals must apply for an employment permit to work. Certain nationalities must then apply for an entry visa to enter Ireland to commence work. Once in Ireland, all non-EEA nationals must apply for an Irish residence permit to register their permission. Non-EEA nationals must renew this Irish residence permission when appropriate.

The first automatic extension of expiring Irish residence permits came into effect March 20 and confirmed that foreign nationals with valid immigration permission due to expire between March 20 and May 20 would be granted an automatic two-month extension.

The second automatic extension of immigration permission for a further two months is a welcome announcement as it provides certainty to employers and employees whose permission was due to expire. This ensures that employees retain their permission under the same conditions during this time.

While the registration offices have been closed, Immigration Service Delivery (ISD) has implemented several COVID-19 responses to mitigate the impact of the closures. They have permitted non-EEA nationals who are eligible to change their permission to apply electronically via email, rather than at an in-person appointment. They have further permitted non-EEA students who are eligible to apply to the Third Level Graduate Programme to apply electronically.

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Update: March 31^th, 2020

Irish Government implements contingency arrangements to process employment permits during the Covid-19 pandemic

What is the change?

Department of Business, Enterprise and Innovation (DBEI), who issue employment permits in Ireland, have published their contingency plan to keep the Employment permits system operational during the COVID-19 pandemic. The plan allows for the online submission of a number of immigration processes and has indicated they will be flexible during this pandemic.

The changes are set to take effect 30 March 2020. There is currently no end date.

Who is affected?

All employers who have non-EEA employees in their workforce or are seeking to hire non-EEA employees during COVID-19

Key Points

• Employment permits will be issued electronically. Authorities will issue PDF versions of Employment permits to the employer, employee and immigration agent. The employment permit will be accompanied by a letter from DBEI. Both the permit and the letter should be kept for verification purposes. Once operations return to normal, the original and certified copies of the employment permit will be distributed to the employer and employee.
• Applications for Stamp 4 letters of Support (renewals of CSEPs) may now be submitted electronically. The form should be submitted to EPStamp4@dbei.gov.ie. Decisions, including grant letters, will be communicated via email. Applications that have recently been submitted by post can be resubmitted online. Applications can be submitted after 20 months of continuous employment on a Critical Skills Employment permit, but will not be processed until after 21 months.
• Appeals may now be submitted electronically. The form should be submitted to EPReviews@dbei.gov.ie. Decisions will be communicated via email.
• Employees retain permission to continue to work whilst renewal is processing. Applications to renew an employment permit cam be submitted between 1-4 months before the expiry of the current permit. Employment permit holders will be allowed to remain in Ireland and continue working while their renewal is processed. Once a new Employment permit is issued, permit holders can apply to the Department of Justice and Equality to update their immigration permission.
• Trusted Partner (renewal and new) applications, Statement of Loss and Transfer of Undertakings can be submitted electronically.
• Rules requiring the surrender of Employment permits have been suspended. Neither companies nor individuals will be required to return employment permits within the standard four-week period after the cessation of employment. DBEI expects that originals and certified copies will be returned only after normal operations resume.
• Accommodations may be made for applicants with pending applications. DBEI has said it can hold applications in the processing queue, change start dates or cancel applications with a full refund if the withdrawal is related COVID-19.
• Applicants from visa-required countries will be contacted about their applications. Ireland has stopped processing of entry visas because of the COVID-19 pandemic. Emergency entry visa applications may be accepted for a limited number of applicants, including for health care professionals or immediate family members of Irish nationals. The suspension of visa issuance, however, will make it impossible for some Employment permit applicants from visa-required countries to enter Ireland at this time. In these cases, both the employer and employee will be contacted. DBEI can hold applications in the queue, amend start dates or return applications with a full refund.
• The Employment permit Section should be contacted by email rather than post.
• Employment permit holders working from home: An employer should send a blanket notification to DBEI.
• Impact on the employment permit in the event of a temporary layoff, reduced working hours or redundancy as a result of covid-19: DBEI should be informed in advance of the temporary layoff/ reduced working hours so that it can be noted on the permit file.  At renewal stage, the salary and working hours as per the conditions of the permit granted may not have been achieved, however, DBEI have noted that where it is related to COVID-19, they will take this into account when considering applications for renewal. The COVID-19 Pandemic Unemployment Payment scheme is available to any employees or self-employed workers, including non-EEA nationals, who lost their job on or after March 13 because of the pandemic. The Temporary COVID-19 Wage Subsidy Scheme, meanwhile, is available to employers to help them keep employees, including Employment permit holders, on payroll throughout the pandemic. Our Deloitte tax team have produced this article to give further information.
• Impact if an employment permit holder has been made redundant: DBEI should be informed of the redundancy within four weeks of the date, via the relevant Redundancy Form. The employment permit holder may seek employment in any eligible occupation and apply for a permit within six months of the date and the Labour Market Needs Test is waived within the six months. The Employer is unable to secure an employment permit for that particular occupation for a period of 6 months.

The contingency plan addresses many of the policy points raised by Deloitte to the Department of Business, Enterprise and Innovation. It will ease immigration procedures for employers and employees impacted by the COVID-19 pandemic. The Department have indicated that they will be flexible on a case by case basis for employers affected by covid-19. Employers are urged to review the plan and reach out to Deloitte for issues or queries that arise as part of their covid-19 planning to ensure that they address any immigration implications. Processing delays should be expected as Employment permits for medical personnel will be prioritised.